[council] EPDP Weekly update

Ayden Férdeline icann at ferdeline.com
Wed Sep 12 09:52:19 UTC 2018


Yes, we had agreed on basic training and in our discussions had spoke of it being of a minimum duration of three to four hours. It was implied that the training would be relevant, tailored to the needs of the EPDP team, and of high quality.

We had not agreed on a 45-minute course that can be breezed through in 15-minutes and which contains little substance.

It surprises me that you think this course will be of value to the EPDP team in any way.

Ayden

> On 12 Sep 2018, at 11:45, Michele Neylon - Blacknight <michele at blacknight.com> wrote:
>
> Ayden
>
> What was agreed was for “basic” training.
>
> What you’ve been demanding goes way beyond that.
>
> And I completely disagree with you trying to blame this on any potential failure of the ePDP.
>
> Regards
>
> Michele
>
> --
>
> Mr Michele Neylon
>
> Blacknight Solutions
>
> Hosting, Colocation & Domains
>
> https://www.blacknight.com/
>
> https://blacknight.blog/
>
> Intl. +353 (0) 59  9183072
>
> Direct Dial: +353 (0)59 9183090
>
> Personal blog: https://michele.blog/
>
> Some thoughts: https://ceo.hosting/
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>
> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>
> From: Ayden Férdeline <icann at ferdeline.com>
> Reply-To: Ayden Férdeline <icann at ferdeline.com>
> Date: Wednesday 12 September 2018 at 10:36
> To: Michele Neylon <michele at blacknight.com>
> Cc: Marika Konings <marika.konings at icann.org>, Council GNSO <council at gnso.icann.org>
> Subject: Re: [council] EPDP Weekly update
>
> We can agree to disagree then.
>
> But I am still going to call it now: the inadequacy of the training provided will contribute to the overall failure of this EPDP.
>
> It will not be the only factor, but it will be one that was within our control to correct.
>
> Ayden
>
>> On 12 Sep 2018, at 11:31, Michele Neylon - Blacknight <michele at blacknight.com> wrote:
>>
>> Ayden
>>
>> We aren’t going to agree on this.
>>
>> I think you are being completely unreasonable in your expectations and that what you are demanding of ICANN is not in line with what we on Council had agreed to.
>>
>> Regards
>>
>> Michele
>>
>> --
>>
>> Mr Michele Neylon
>>
>> Blacknight Solutions
>>
>> Hosting, Colocation & Domains
>>
>> https://www.blacknight.com/
>>
>> https://blacknight.blog/
>>
>> Intl. +353 (0) 59  9183072
>>
>> Direct Dial: +353 (0)59 9183090
>>
>> Personal blog: https://michele.blog/
>>
>> Some thoughts: https://ceo.hosting/
>>
>> -------------------------------
>>
>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>>
>> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>>
>> From: Ayden Férdeline <icann at ferdeline.com>
>> Reply-To: Ayden Férdeline <icann at ferdeline.com>
>> Date: Wednesday 12 September 2018 at 10:24
>> To: Michele Neylon <michele at blacknight.com>
>> Cc: Marika Konings <marika.konings at icann.org>, Council GNSO <council at gnso.icann.org>
>> Subject: Re: [council] EPDP Weekly update
>>
>> Michele,
>>
>> I am aware that “ICANN is not a training academy.”
>>
>> But I do not think it is unreasonable for ICANN org to provide participants in a working group that benefits, primarily, ICANN with a basic degree of training that will assist these participants in going about their work.
>>
>> Most EPDP members do not have a need for the GDPR training, aside from for this one activity that they are doing on an unremunerated basis for the primary benefit of ICANN.
>>
>>> I also suspect you are confusing people’s lack of understanding with their will to accept reality.
>>
>> I can hardly conclude that they are refusing to accept reality when I know for certain they have not been given sufficient training in how to interpret and apply the GDPR.
>>
>> Ayden
>>
>>> On 12 Sep 2018, at 11:02, Michele Neylon - Blacknight <michele at blacknight.com> wrote:
>>>
>>> Ayden
>>>
>>> ICANN is not a training academy.
>>>
>>> I also suspect you are confusing people’s lack of understanding with their will to accept reality.
>>>
>>> Regards
>>>
>>> Michele
>>>
>>> --
>>>
>>> Mr Michele Neylon
>>>
>>> Blacknight Solutions
>>>
>>> Hosting, Colocation & Domains
>>>
>>> https://www.blacknight.com/
>>>
>>> https://blacknight.blog/
>>>
>>> Intl. +353 (0) 59  9183072
>>>
>>> Direct Dial: +353 (0)59 9183090
>>>
>>> Personal blog: https://michele.blog/
>>>
>>> Some thoughts: https://ceo.hosting/
>>>
>>> -------------------------------
>>>
>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>>>
>>> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>>>
>>> From: Ayden Férdeline <icann at ferdeline.com>
>>> Reply-To: Ayden Férdeline <icann at ferdeline.com>
>>> Date: Wednesday 12 September 2018 at 09:56
>>> To: Michele Neylon <michele at blacknight.com>
>>> Cc: Marika Konings <marika.konings at icann.org>, Council GNSO <council at gnso.icann.org>
>>> Subject: Re: [council] EPDP Weekly update
>>>
>>> Michele,
>>>
>>> Yes, I think this training is required, because it is not apparent that all members of the EPDP have the appropriate baseline of knowledge of relevant data protection regulations.
>>>
>>> And this lack of knowledge is delaying the work of the EPDP, increasing its overall cost, and will only expose ICANN org and the contracted parties to harm.
>>>
>>> Of course "there is nothing to stop people independently seeking and getting their own supplemental training,” but guess what, they’re not - so ICANN needs to provide it.
>>>
>>> Ayden
>>>
>>>> On 12 Sep 2018, at 10:49, Michele Neylon - Blacknight <michele at blacknight.com> wrote:
>>>>
>>>> Ayden
>>>>
>>>> I think your “ask” is at odds with what we discussed at length during the drafting of the ePDP’s charter.
>>>>
>>>> There was never any expectation that ICANN would provide and fund the kind of comprehensive and in depth GDPR training that you have been demanding.
>>>>
>>>> It is my understanding that it was agreed that a basic course like the one that has been identified be provided. That is being supplemented by Becky Burr.
>>>>
>>>> I also note that your posts on the ePDP mailing list go into greater detail about what you expect a course to cover and to be frank I’m amazed you’d think that ICANN would be the venue for this kind of training. (seehttps://mm.icann.org/pipermail/gnso-epdp-team/2018-September/000328.html )
>>>>
>>>> It was discussed that “basic” training would be provided and I believe that this is being done. Also there is nothing to stop people independently seeking and getting their own supplemental training.
>>>>
>>>> Regards
>>>>
>>>> Michele
>>>>
>>>> --
>>>>
>>>> Mr Michele Neylon
>>>>
>>>> Blacknight Solutions
>>>>
>>>> Hosting, Colocation & Domains
>>>>
>>>> https://www.blacknight.com/
>>>>
>>>> https://blacknight.blog/
>>>>
>>>> Intl. +353 (0) 59  9183072
>>>>
>>>> Direct Dial: +353 (0)59 9183090
>>>>
>>>> Personal blog: https://michele.blog/
>>>>
>>>> Some thoughts: https://ceo.hosting/
>>>>
>>>> -------------------------------
>>>>
>>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>>>>
>>>> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>>>>
>>>> From: council <council-bounces at gnso.icann.org> on behalf of Ayden Férdeline <icann at ferdeline.com>
>>>> Reply-To: Ayden Férdeline <icann at ferdeline.com>
>>>> Date: Tuesday 11 September 2018 at 19:39
>>>> To: Marika Konings <marika.konings at icann.org>
>>>> Cc: Council GNSO <council at gnso.icann.org>
>>>> Subject: Re: [council] EPDP Weekly update
>>>>
>>>> Thank you for the response, Marika. I have shared two emails on the EPDP team list over the past 24 hours regarding the GDPR training, neither of which you responded to. I suspect if you posted this same message there, there would be a high level of disagreement between EPDP members and ICANN org over the approach that you seem to think was endorsed by the EPDP team.
>>>>
>>>> Check the transcript. On 7 August I initially requested GDPR training, and a week later, Stephanie Perrin made the request too. As you might recall, the Council also discussed this matter when drafting the charter for the EPDP. The need for training had been raised by Martin, myself, and supported by others. Why, then, was the request only actioned when requested by RySG a month later?
>>>>
>>>> It is true that the EPDP team was made aware of the names of two providers on the call of 6 September. We were not, however, consulted on the course itself or its contents, and no details were forthcoming. Again, check the Adobe Connect chat and the questions that were ignored and the short responses given. I personally visited the website of ITgovernance after its name was circulated and no where on the homepage or on their GDPR training page did I find this £20 course. I don’t see it there today either. I saw and continue to see more comprehensive options. We attempted to clarify with ICANN staff that we were getting a course that would offer at least “three-four hours” of training but received no response. Ultimately staff have selected one which is supposed to take 45 minutes but can be breezed through in 15.
>>>>
>>>> As for the course being shared with the EPDP team leadership, perhaps that was so, but they did not share it with EPDP members and neither member of the leadership team are themselves GDPR experts. Perhaps they should have consulted with EDPD members before this course was procured. I had actually suggested to the Council liaison that this happen, but it did not.
>>>>
>>>> The course is not adequate and should never have been purchased.
>>>>
>>>> —Ayden
>>>>
>>>>> On 11 Sep 2018, at 20:17, Marika Konings <marika.konings at icann.org> wrote:
>>>>>
>>>>> To provide some context as Council members consider Ayden's input, a request was made by the RySG, and supported by the EPDP Team, for GDPR training. Several suggestions were made for possible training providers by EPDP Team members. Staff gathered input on these options, including costs and content covered, which was subsequently shared with the EPDP Team leadership who recommended moving forward with the training provided by IT governance (one of the providers recommended by one of the EPDP Team members) followed by a Q & A session with Becky Burr that will allow for members to put forward any additional questions they may have. The recommended approach was shared with the EPDP Team during its meeting on 6 September during which no objections were raised, following which the training was procured and distributed to members, alternates and liaisons. The Q & A session with Becky is scheduled for Wednesday 19 September.
>>>>>
>>>>> Best regards,
>>>>>
>>>>> Marika
>>>>>
>>>>> From: council <council-bounces at gnso.icann.org> on behalf of Ayden Férdeline <icann at ferdeline.com>
>>>>> Reply-To: Ayden Férdeline <icann at ferdeline.com>
>>>>> Date: Tuesday, September 11, 2018 at 12:03
>>>>> To: "darcy.southwell at endurance.com" <darcy.southwell at endurance.com>, 'Rafik Dammak' <rafik.dammak at gmail.com>, 'Council GNSO' <council at gnso.icann.org>
>>>>> Subject: Re: [council] EPDP Weekly update
>>>>>
>>>>> I encourage members of the Council to research the £20 ($25), 45-minute GDPR course that EPDP members have been offered, and to evaluate whether you think this will leave the EPDP team on the right footing to develop a policy that does expose ICANN org and the contracted parties to unwanted liabilities. It is my humble view that the training is inadequate and not suitable for our purposes. The course was procured without EPDP team consultation and is intended for frontline individual contributors who occasionally come across personal data, not for those designing a policy or system. I think ICANN org has done us a great disservice in procuring this course. It’s not disappointing; I think the more accurate descriptor would be "reckless."
>>>>>
>>>>> Ayden
>>>>>
>>>>> On Tue, Sep 11, 2018 at 19:45, Darcy Southwell <darcy.southwell at endurance.com> wrote:
>>>>>
>>>>>> Thanks, Rafik.  Have a couple of questions from your update:
>>>>>>
>>>>>> ·       What is the deadline for EPDP members to complete the training?
>>>>>>
>>>>>> ·       You noted the project is behind, and I see the items highlighted in yellow as "manageable delay/issue."  You agree that these are manageable?  I wasn’t sure from your update.
>>>>>>
>>>>>> Thanks,
>>>>>>
>>>>>> Darcy
>>>>>>
>>>>>> From: council [mailto:council-bounces at gnso.icann.org] On Behalf Of Rafik Dammak
>>>>>> Sent: Monday, September 10, 2018 10:31 AM
>>>>>> To: Council GNSO <council at gnso.icann.org>
>>>>>> Subject: [council] EPDP Weekly update
>>>>>>
>>>>>> hi all,
>>>>>>
>>>>>> please find the EPDP update of last week. Happy to answer questions.
>>>>>>
>>>>>> Best Regards,
>>>>>>
>>>>>> Rafik
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